In August 2015, OSHA updated its National Emphasis Program (NEP) on Amputations.  Based on a review of data from general industry as well as targeted industries, OSHA determined that workplace amputations were being underreported.  OSHA updated the NEP on Amputations to target all workplaces with machinery or equipment capable of causing amputations.

OSHA defines “amputation” as follows:

An amputation is the traumatic loss of a limb or other external body part. Amputations include a part, such as a limb or appendage, that has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; amputations of body parts that have since been reattached. Amputations do not include avulsions, enucleations, deglovings, scalpings, severed ears, or broken or chipped teeth.

29 C.F.R. § 1904.39(b)(11).  Amputations have become a priority – in January 2015, a new rule came into effect requiring employers to report amputations within 24 hours to the nearest OSHA Area office, the OSHA toll-free number, or through OSHA’s online reporting system.

The updated NEP establishes procedures to help identify and reduce machine and equipment hazards that are likely to cause amputations.  The NEP includes targeting/selection, inspection, and outreach activities.

OSHA Area and Regional offices will develop targeted lists for inspection, including general industry establishments where amputations have occurred due to machinery or equipment in the last five years.  Area offices will schedule inspections, which may include inspections of machinery or equipment and potential employee exposures during certain activities, such as regular operation, cleaning, or clearing jams or upset conditions.  Pre-inspection outreach is required for newly targeted establishments.

The NEP provides a list of machinery and equipment of particular interest (which is not inclusive).  The list includes aerial lift platforms, cranes, conveyors, extruding machinery, metal and woodworking machinery, and presses.  A complete list can be found in Appendix A of the NEP.

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Photo of Megan Baroni Megan Baroni

I am an environmental attorney in Robinson+Cole’s Environmental and Utilities Group. I have worked with manufacturers, both big and small, on environmental compliance, risk management, and litigation matters for my entire career. My full firm bio can be accessed here.

As an…

I am an environmental attorney in Robinson+Cole’s Environmental and Utilities Group. I have worked with manufacturers, both big and small, on environmental compliance, risk management, and litigation matters for my entire career. My full firm bio can be accessed here.

As an environmental lawyer, I never want to be a roadblock to our client’s goals. I strive to understand the business of our manufacturing clients – what do you make and how do you make it? I want to know your objective, and I want to help you get there. Regulatory requirements and potential legal liabilities can sometimes seem daunting, but I help our clients develop an understanding of the requirements and all of the potential options so that we can create practical and cost-effective solutions to accomplish the objective. I work with management as well as the people who make our clients’ products every day, and I enjoy every part of it. It’s a good day for me when I can put on my hard hat and walk the factory floor.